"This paper deals with the transfer taxes which are levied are generally levied on the transfer of all types of real property, including residential, commercial, and agricultural property. It also states various types of property transfer taxes. In New Mexico gross receipts taxes are currently imposed on all of the...
Byline: Mindy Piatoff Nov 13, 2006 (Tax Planning International Transfer Pricing - ABIX via COMTEX) -- The Internal Revenue Service views transfer pricing and the offshore transfer of intangibles as among the biggest US tax compliance problems. The tax departments of multinationals treat...
Byline: Soula McFall Jan 29, 2007 (Tax Notes International - ABIX via COMTEX) -- The Australian Taxation Office ATO has an unlimited time in which it can amend tax assessments in regard to transfer pricing. This is in spite of the fact that it...
Congress has tinkered with transfer taxes for almost 50 years. On June 7, 2001 the President signed into law The Economic Growth and Tax Relief Reconciliation Act of 2001. The new law has far reaching effects on individual, retirement and estate taxes. But, an analysis of Tax Act 2001 reveals...
PICTURE A TRAIN CARRYING THREE BOXCARS OF INFORMATION YOUR COMPANY GENERATED FOR TAX LITIGATION OVER TRANSFER PRICING. NOW IMAGINE YOURSELF RESOLVING THE SAME ISSUE WITH THREE BINDERS OF INFORMATION. TO AVOID HAVING TO PREPARE A TRAINLOAD OF DOCUMENTATION TO DEFEND YOUR TRANSFER PRICING PRACTICES, READ ON TO LEARN HOW YOU...
ALISO VIEJO, Calif. -- GTREX Capital, Inc. (OTCBB:GRXI) today announced that it has appointed Transfer Online as its new Transfer Agent and Registrar in order to improve its operational competency and make a wider range of electronic services available for its shareholders. Transfer Online provides direct online information to both...
Jul 31, 2006 (International Tax Review - ABIX via COMTEX) -- In many countries, transfer pricing activities are subject to OECD guidelines and the OECD Model Tax Convention on Income and Capital. Both the guidelines and the model suggest the arm's le Jul 31, 2006 (International...
Feb 02, 2006 (Australian Property Investor Magazine - ABIX via COMTEX) -- The Australian Taxation Office ATO has a range of publications available for those needing information on the tax issues ...
Jul 31, 2006 (International Tax Review - ABIX via COMTEX) -- The cross-border use of capital creates certain tax issues. One of such issues is the need to compensate the capital possessor in certain situations. This issue has recently been dealt with in a discussion...
Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return, is the Federal form used to report gifts. Some gifts are subject not only to gift tax, but also to generation-skipping transfer GST tax. Background The Sec. 2601 GST tax is...
A major tax issue that faces modern multinational corporations is cross-border transfer pricing. Some one third of international trade is composed of intra-group transfers, with different national rates of corporate income tax creating possibilities for the loss of national revenues. Some critical tax implications of corporate transfer pricing policies are...
Transfer pricing and tax havens, individually and in combination, adversely affect the ability of many countries to raise tax revenues. The problem is especially severe in less developed countries LDCs and in countries in transition from socialism CITs, which is generally lumped together and designate as LDCTs. This paper describes...
Transfer pricing is the most important international tax issue that multinational enterprises MNEs now face, according to a recent survey by Ernst & Young. Eighty-six per cent of MNE parent company respondents and 93% of subsidiary respondents to the Ernst & Young Transfer Pricing 2003 Global Survey identified transfer...
Oct 13, 2003 (Weekly Tax Bulletin - ABIX via COMTEX) The Australian Taxation Office ATO issued Taxation Determination TD 2003/23 on 1 October 2003. The Determination concerns the transfer of an additional tax loss under section 170A of the Income Tax Assessment Act 1997...
Feb 08, 2006 (REM Real Estate Magazine - ABIX via COMTEX) -- The transfer of property in Australia generally attracts the capital gains tax CGT. If a person gives a property to ...
The article offers an overview of credit derivatives, a summary of accounting and operational issues, and surveys of the tax treatment of credit derivatives in the countries that participated. It also covers a wide range of tax and legal issues including the status of vehicle for tax purposes; taxation of...
Where Merrill Lynch & Co., Inc. appealed a tax court determination that Merrill had deficiencies in its 1997 and 1998 tax payments because it improperly claimed capital gains losses under Section 301 of the Internal Revenue Code IRC for a series of inside and outside sales among its subsidiaries, the...
Byline: Neil Wilson May 11, 2007 (International Tax Review - ABIX via COMTEX) -- Australia's transfer pricing rules have been in operation for 25 years. According to the Australian Taxation Office, transfer pricing poses a risk to tax revenue collection, due to its complexity...
If any organization, like many US companies, is eying the Canadian marketplace for expansion opportunities, they would be well advised to integrate transfer pricing into strategic business planning. As global business growth sets a blistering pace, Canada, like many other high-tax jurisdictions, has noted a worrying increase in capital moving...
Byline: Lee A Sheppard Feb 05, 2007 (Tax Notes International - ABIX via COMTEX) -- Transfer pricing is the point at which poor tax policy and poor tax administration meet. Intangibles often cause problems in transfer pricing. Temporary and proposed section 482 services regulations...
